Dickerson v. Johnson

• Court: District Court, District of Columbia
• Decided: April 17, 2026
• Docket: Civil Action No. 2025-4405
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MICHELLE MARRYANN DICKERSON,

Plaintiff,

v. Civil Action No. 25-4405 (UNA)

MIKE JOHNSON, et al.,

Defendants.

Memorandum Opinion

Plaintiff, proceeding pro se, brings this action against Speaker of the U.S. House of

Representatives Mike Johnson and 130 state and federal judges and justices, alleging they are

engaged in a criminal enterprise that traffics and abuses children. ECF No. 1. She has also filed a

motion for leave to proceed in forma pauperis. ECF No. 2. For the reasons below, the court grants

the motion to proceed in forma pauperis and dismisses the complaint without prejudice for lack of

subject-matter jurisdiction.

A court may dismiss a complaint sua sponte for lack of subject-matter jurisdiction. See

Fed. R. Civ. P. 12(h)(3); see also 28 U.S.C. § 1915(e)(2)(B)(i). When a complaint is “‘patently

insubstantial,’ presenting no federal question suitable for decision,” the court lacks authority to

hear the case and dismissal is warranted. Best v. Kelly, 39 F.3d 328, 330 (D.C. Cir. 1994) (quoting

Neitzke v. Williams, 490 U.S. 319, 327 n.6 (1989)). That standard includes cases that are “so

attenuated and unsubstantial as to be absolutely devoid of merit.” Hagans v. Lavine, 415 U.S. 528,

536–37 (1974) (quoting Newburyport Water Co. v. Newburyport, 193 U.S. 561, 579 (1904)); see

also Tooley v. Napolitano, 586 F.3d 1006, 1010 (D.C. Cir. 2009) (collecting cases dismissed “for patent insubstantiality,” including where the plaintiff allegedly “was subjected to a campaign of

surveillance and harassment deriving from uncertain origins”).

Here, the complaint’s allegations are patently insubstantial and deprive the court of

jurisdiction to hear the case. For example, the complaint alleges that Chief Justice John Roberts

“[e]nrich[es] himself through the commodification of children” by participating in “judicial

kidnapping” and a “conspiracy to maintain a racketeering enterprise.” ECF No. 1 at 39. It further

alleges that Defendants’ “enterprise . . . orchestrat[es] mass trafficking that constitutes a genocide

of children on a global scale.” Id. at 44. According to the complaint, this “Judicial Racket

Enterprise” has “systematically weaponized Title IV funding, guardianship proceedings, and

custody litigation to traffic children, launder federal funds, and silence dissent.” Id. at 53. The

complaint alleges that “[b]eyond trafficking, the enterprise perpetuated acts of cannibalism and

other grotesque abuses shielded by the absence of explicit federal prohibition on cannibalism and

further protected by wealth, secrecy, and corrupt judicial mechanisms.” Id. at 46. These allegations

are similar to those that courts have routinely dismissed for “patent insubstantiality.” Tooley, 586

F.3d at 1010 (collecting cases).

For these reasons, the court grants the motion to proceed in forma pauperis, ECF No. 2,

and dismisses the complaint without prejudice for lack of subject-matter jurisdiction. A separate

order accompanies this memorandum opinion.

/s/

AMIR H. ALI United States District Judge Date: April 16, 2026